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Home My WebLink About14-3362• S E C T I 0 N A S C T I 0 N B Supreme Coourt;o ;;Pennsylvania Cour(Of Common'P,leas Civil. CoyerShee CUMBERLAN' County••,�t 30286820 C A Pit SJS �V VR # For Prothonotan' Use On4,: DISCOVER BANK Lead Plaintiff's Name: ; �'• s Docket No:' /' .v ) The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: el Complaint ❑ Writ of Summons 0 Petition ❑ Transfer from Another Jurisdiction 0 Declaration of Taking DISCOVER BANK Lead Plaintiff's Name: Lead Defendant's Name: MICHAEL D COOPER Are money damages requested? El Yes 0 No Dollar Amount Requested: ® within arbitration limits (check one) ❑ outside arbitration limits Is this a Class Action Suit? 0 Yes al No Is this an 1VIDJ Appeal? • Yes El No William T. Molczan,47437 Name of Plaintiff /Appellant's Attorney: 0 Check here if you have no attorney (are a Self -Represented [Pro Se] Litigant) Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) ❑ Intentional ❑ Malicious Prosecution ❑ Motor Vehicle ❑ Nuisance ❑ Premises Liability o Product Liability (does not include Mass tort) ❑ Slander/Libel/Defamation ❑ Other: MASS TORT ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort — Implant ❑ Toxic Waste ❑ Other: PROFESSIONAL LIABILITY ❑ Dental ❑ Legal O Medical ❑ Other Professional: CONTRACT (do not include Judgments) uyer Protection Debt Collection: Credit Card O Debt Collection: Other O Employment Dispute Discrimination ❑ Employment Dispute: Other O Other: REAL PROPERTY ❑ Ejectment ❑ Eminent Domain/Condemnation ❑ Ground Rent ❑ Landlord/Tenant Dispute ❑ Mortgage Foreclosure: Residential ❑ Mortgage Foreclosure: Commercial ❑ Partition ❑ Quiet Title ❑ Other: CIVIL APPEALS Administrative Agencies ❑ Board of Assessment ❑ Board of Elections ❑ Dept. of Transportation ❑ Statutory Appeal: Other ❑ Zoning Board ❑ Other: MISCELLANEOUS ❑ Common Law/Statutory Arbitration ❑ Declaratory Judgment ❑ Mandamus ❑ Non -Domestic Relations Retraining Order ❑ Quo Waranto ❑ Replevin ❑ Other: Updated 1/1/2011 iflE HON 2. 014 JU;.j —4 o ;: 1 7 CUMBERLAND COUQ� Y PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DISCOVER BANK Plaintiff vs. MICHAEL D COOPER CIVIL DIVISION /y 3/,02 COMPLAINT IN CIVIL ACTION Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan,47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Ave Ste 1400 Pittsburgh PA 15219-1827 (412) 434-7955 FAX: 412-338-7130 30286820 C A Pit SJS 0A,4_ ta103.75�� IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Civil Action No COMPLAINT AND NOTICE TO DEFEND DISCOVER BANK Plaintiff vs. MICHAEL D COOPER Defendant You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, Discover Bank, is a banking institution organized under the laws of the State of Delaware and maintains a business address of 12 Reads Way, New Castle, DE 19720. 2. DB Servicing Corporation is the servicing affiliate for Discover Bank, f/k/a Greenwood Trust Company, an FDIC -insured Delaware State bank. As the servicing affiliate, DB Servicing Corporation performs a variety of services for Discover Bank including, business management services in support of Discover Bank business lines, including, among other things, credit cards, deposits, personal loans and student loans, customer service, collections, credit risk, collection of delinquent accounts and other support services. The collection of delinquent accounts includes the right to forward the account to the attorneys and/or collection agencies for collection and to file suit on Discover Bank's behalf. 3. At all times pertinent hereto, DB Servicing Corporation is the servicing affiliate for Discover Bank, in reference to Defendant's account, which is the subject of this litigation. 4. Defendant is an adult individual(s) residing at 59 E MAIN ST MECHANICSBURG, PA 17055 5. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX1169. 6. Defendant made use of said credit card and has a current balance due of $12086.00. A copy of Plaintiff's Statement is attached hereto, marked as Exhibit "1". 7. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 8. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due the Plaintiff. WHEREFORE, Plaintiff prays for Judgment in its favor and against Defendant, MICHAEL D COOPER, INDIVIDUALLY, in the amount of $12086.00 and costs. /// 1 William T. Moan,47437 WELTMAN, WEIN RG & REIS CO., L.P.A. 436 7th Ave Ste 1400 Pittsburgh PA 15219-1827 (412) 434-7955 FAX: 412-338-7130 WWR# 30286820 C A Pit SJS DISC VER ACCOUNT SUMMARY Previous Balance $12,086.00 Payments and Credits — $0.00 Purchases + $0.00 Balance Transfers + $0.00 Cash Advances + $0.00 Fees Charged + $0.00 Interest Charged + $0.00 New Balance $12,086.00 See Interest Charge Calculation section following the Transactions section for detailed APR information Credit Line $0 Credit Line Available SO Cash Advance Credit Line 50 Cash Advance Credit Line Available SO You may be able to ovoid interest on Purchases. See reverse for details. Contact Us Discover.com 1-800-347-2683 Make Check payable io Discover Please fold on the perforation below, detach and return with your payment Discover More Card Account number ending in 1 169 Open Date: Oct 16, 2013- Close Date: Nov 15, 2013 Cardmember Since 2011 PAYMENT INFORMATION New Balance Minimum Payment Due * Payment Due Date ` Includes past due amount of: Page 1 of 4 $12,086.00 $12,086.00 December 10, 2013 53160.00 Late Payment Warning: If we do not receive your minimum payment by the date listed above, you may have to pay a late fee of up to $35.00 and your purchase and balance transfer APRs for new transactions may be increased up to the Penalty APR of 25.99% variable. Minimum Payment Warning: If you make only the minimum payment each period, you will pay more in interest and it will take you longer to pay off your balance. For example: f' you ruoke rats edd+nor.oi zfto s A+sd you will ertd a sing dtrt tnd each.rnonifi paying art eslirrrratecifoia • Only the minimum payment 11 years $12,086 l f you would like information about credit counseling services, call 1-800-347-1121. 1 You fsoya:ifig, faolar�ce shown ort flits 1citetnenrith about;., REWARDS Cashback Bonus@ Opening Balance New Cashback Bonus This Period Redeemed This Period Cashback Bonus Balance To learn more, log in at Discover.com Anniversary Month August $ 0.00 + $ 0.00 — $ 0.00 $ 0.00 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION Payment Coupon Pay Online Please do Hilt old.;; clip or.atople, f iscovertom pay by Phorte ~I -10.44 ;'*683 I1IIIII;i1;IIj111111'lll'I MICHAEL D COOPER 3912 ROSEMONT AVE CAMP HILL PA 17011-7813 (iljllll 1il'1i11l'1I. 30286820J Internet payments must be received by 5PM ET to be credited as of the same day .• Address, e-mail or_ielephone changed? Note changes. on reverse side Account number ending in 1169' Minimum Payment Due $12,086.00 New Balance $12,086.00 Payment Due Date Amount enclosed PO BOX 6103. CAROL STREAM IL 60197-6103 1;11111111 000001986458189924653120860000019801208600 December 10, 2013 I$ 1 1 1 1 1 1111 Ii iii��I: it 11 � I I I: ,�i� (i� �� IIS1(IIIA` I EXHIBIT MICHAEh D COOPER . Account 'number endin0.in 1169 Important Information See your Cardmember Agreement. Your Card member Ag reement contains all the terms of your Account. Lost or stolen cards. Report immediately! Coll 1-800-347-2683. What To Do If You Think You Find A Mistake On Your Statement If you think there is an error on your statement, write to us at: Discover, PO Box 30421, Solt Lake City, UT 84130-0421. You must write to us within 60 days after the error appeared on your statement. You may call us, but if you do we ore not required to investigate any potential errors, and you may have to pay the amount in question. The Billing Rights Notice further explains your rights. Please see your Cardmember Agreement or visit https://discover.com/billingrights for a copy of this notice. Payments. You may pay all or part of your Account balance at any time. However, you must pay at least the Minimum Payment Due by the Payment Due Date. Send only your payment and the bottom portion of this statement in the envelope provided after affixing postage. Payments sent without proper postage will be returned to the sender. Do not send cosh. If you pay by check, you authorize us to use information on your check to make on electronic fund transfer from your account at the financial institution indicated on your check or to process the payment as a check transaction. If a payment is processed as an electronic fund transfer, the transfer will be for the amount of the check. When we use information from your check to make an electronic fund transfer, funds may be withdrawn from your account as soon as the same day we receive your payment, and you will not receive your check bock from your financial institution. The processing of your payment may be delayed if you send cosh, corres- pondence or other items with your payments, if you send the payment to any other address, or if you use an envelope other than the one provided. Payments received in proper form at our processing facility by 5PM local time on any day will be credited to your Account as of that day. Payments received at our processing facility after 5PM local time will be credited to your Account as of the next day. If you hove misplaced your envelope, send your payment to Discover, PO Box 6103, Carol Stream, IL 60197.6103. Please allow 7.10 days for delivery. If your payment is returned unpaid, we reserve the right to resubmit it as an electronic debit. Payments made online or by phone will be credited as of the day of receipt if mode by 5 PM Eastern time. You can pay your monthly Minimum Payment Due, or a greater amount that does not exceed your current Account balance, over the telephone or you can setup automatic payments through a customer service representative by calling 1-800-347-2683. Automatic payments for the billing period shown on your statement will be deducted on the Payment Due Dote shown on that statement, or the next automatic payment date referred to on your statement, unless you request a recurring payment dote (e.g., the 15'h day of the month) that occurs before your Poyment Due Date or Close Dote. If your scheduled payment dale falls on a weekend or bank holiday, your payment will be processed the business day prior to the weekend or bank holiday. In order to schedule monthly payments by telephone, you will need this statement and your bank account information. You will be asked to provide the last four (4) digits of the social security number of the primary borrower. By providing those numbers as your electronic signature, you will be ogreeing to this authorization to allow us and your bank to deduct each payment you authorize, in the amount selected by you, from your bank account. You also authorize us to initiate debit or credit entries to your bank account, as applicable, to correct an error in the processing of such payment. You can cancel a scheduled payment by phone at 1-800-347-2683 or by mail at Discover, PO Box 30421, Salt Lake City, UT 84130-0421; however, we must receive notice at least three business days in advance of the scheduled payment. If your payments may vary in amount, we will tell you on each monthly billing statement when your payment will be made and how much it will be. CHANGE OF ADDRESS Open Date: Oct 16, 2013 - Close Dote: Nov 15, 2013 Page 2 of 4 You must ensure that sufficient funds are available in your bank account, and all transactions must comply with U.S. law. You can set automatic payments for: (i) statement New Balance, (ii) statement Minimum Payment Due, (iii) statement Minimum Payment Due plus a fixed dollar amount, or (iv) Other dollar amount. If your scheduled "Other dollar amount' payment is not enough to cover the Minimum Payment Due as listed on your monthly billing statement, your scheduled payment for that month will be increased to cover the Minimum Payment Due. If the scheduled payment is greater than the Minimum Payment Due, any excess will be applied in accordance with your Cardmember Agreement. If your scheduled payment is greater than the New Balance on your billing statement, that payment will be processed only for the amount of your New Balance. Your automatic payment amount may be less than the amount indicated on the billing statement based on credits or payments after the Close Date. If you enroll by phone in our automatic payment service, please fill-in the following blanks below and retain the authorization for your records. Amount: 0Full Pay 0Min Pay LJMin Pay+ $ LI Other Amounts ; Bank Routing #: Bank Account # Monthly on the 0 Payment Due Date L Close Date 0 Day of month (insert dale) Credit Reporting. We may report information about your Account to credit bureaus. Late payments, missed payments, or other defaults on your Account may be reflected in your credit report. We normally report the status and payment history of your Account to credit reporting agencies each month. If you believe that our report is inaccurate or incomplete, please write us at this address: Discover, PO Box 15316, Wilmington, DE 19850-5316.PIease include your name, address, home telephone number and Account number. Paying Interest. Your due date is at least 25 days after the close of each billing period (at least 23 days for billing periods that begin in February). We will not charge you any interest on Purchases if you pay your entire balance by the due dote each month. We will begin charging interest on Cosh Advances and Balance Transfers as of the later of the Transaction Date or the first day of the billing period in which the transaction posted to your Account. How We Calculate Interest Charges. We Use the Daily Balance Method (including current transactions) to calculate the Balance Subject to Interest Rote. For more information, please cull us of 1-800-347-2683. Balance Subject to Interest Rate. Your statement shows a Balance Subject 10 Interest Rafe. 11 shows this for each transection category. The Balance Subject to Interest Rate is the average of the daily balances during the billing period. Credit Balances. If your Account has a credit balance, the amount is shown on the front of your billing statement. A credit balance is money that is owed to you. You may make charges against this amount if your Account is open. We will send you a refund of any remaining balance of 51.00 or more after 6 months, or as otherwise required by applicable law, or upon request mode io the address in the Contact Us section on page 3 of your billing statement. Balance Transfers. Balance Transfers are offered at our discretion and accrue interest at the standard purchase role unless we tell you otherwise. Discover may monitor and/or record telephone calls between you and Discover representatives for quality assurance purposes. The Discover® card is issued by Discover Bonk, Member FDIC. TL23N If correct on front, do not use. Please print clearly in blue or black ink, in the space provided. Street Address City 36 g��20 Home Phone Work Phone Email To make changes to your address, email or telephone number, visit Discover.com Continued on next page DISC VER CONTACT US Web Access your account securely at Discover.com Mobile Manage your account anytime, anywhere at m.Discover.com Phone 1 -800 -DISCOVER (1-800-347-2683) TDD 1-800-347-7449 Discover More Card. Account number ending in 1 169 Open Date: Oct 16; 2013'- Close Date: Nov 15, 2013'. Page 3 of 4 Inquiry Mail Payments Discover Discover PO Box 30943 PO Box 6103 Sall Lake City Carol Stream UT 84130 IL 60197-6103 Transactions Trans. Date Post Date Fees TOTAL FEES FOR THIS PERIOD 0.00 Interest Charged TOTAL INTEREST FOR THIS PERIOD $ 0.00 2013 Totals Year -to -Date TOTAL FEES CHARGED IN 2013 TOTAL INTEREST CHARGED IN 2013 $ 210.00 5 1,210.90 Interest Charge Calculation Your Annual Percentage Rate (APR) is the annual interest rate on your account. Current Billing Period: 31 days ANNUAL PERCENTAGE RATE BALANCE SUBJECT TO TYPE OF BALANCE (APR) INTEREST RATE INTEREST CHARGE Purchases 20.99% V $0.00 50.00 Cash Advances 23.99% V $0.00 50.00 V=Voriable Rate Information For You For more information about how interest charges are calculated see your Cardmember Agreement or go to www.discover.com/interestcharges 30286820 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION .MICHAEL D COOPER 30286820.. Account number ending in 1.169 Open Date: Ocl_16, 2013 - Close Date: Nov 15, 2013 Page 4 of 4 (Name) VERIFICATION f+L 1--(r1011\ c� Dr6 l`-C�k((Title of DB Servicing Corporation, servicing affiliate of Discover Bank does hereby verify, under penalty of perjury and subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsifications to authorities states, that he/she is a duly authorized representative of plaintiff herein. Additionally, he/she verifies that Discover Bank, f/k/a Greenwood Trust Company, which is an FDIC -insured Delaware state bank, lacks sufficient knowledge or information to verify this complaint. He/she verifies that he/she is authorized to make this verification. As an employee of DB Servicing Corporation, he/she has sufficient knowledge and information to make this verification, and consequently verifies that the facts set forth in the foregoing complaint are true and correct to the best of his/her knowledge and information and that he/she is personally familiar with the account and the relationship between Discover Bank and DB Servicing Corporation. It is further stated that Discover Bank and DB Servicing Corporation extend credit through issuance of the Discover Card. As the servicing affiliate, DB Servicing Corporation performs a variety of services for Discover Bank, including business management services in support of Discover Bank business lines, including, among other things, credit cards, deposits, personal loans and student loans, customer service, collections, credit risk, collection of delinquent accounts and other support services. The collection of delinquent accounts includes the right to forward the same to the attorneys and/or collection agencies for collection and to file suit on Discover Bank's behalf. Both DB Servicing Corporation and Discover Bank are wholly owned subsidiaries of Discover Financial Services. Date Shlzll`f MICHAEL D COOPER XXXXXXXXXXXX116 9 WWR# 30286820 C A Pit SJS wJl DB Servicing Corporation servicing affiliate For Discover Bank SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith 00e Chief Deputy ` jT 11 27 PH 2: Richard W Stewart f;l,JalBr-1q;( ,';;.4D U;J Solicitor z ,. f h E t4 N S Y I V J%� l A Discover Bank vs. Case Number Michael D Cooper 2014-3362 SHERIFF'S RETURN OF SERVICE 06/20/2014 06:32 PM - Deputy Shawn Harrison, being duly sworn according to law, served thpqequested Complaint & Notice by handing a true copy to a person representing themselves toAs y Oraham, girlfriend of defendant, who accepted as"Adult Person in Charge"for Michael D Cq6pbr at 9 E Main Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. S WN R IS , DEP TY SHERIFF COST: $50.60 SO ANSWERS, June 23, 2014 RON R ANDERSON, SHERIFF w"" a if I DISCOVER BANK Plaintiff vs. MICHAEL D COOPER TO THE PROTHONTARY: CUMBERLANDCOUNTY,PENNSYLVANIA IN HCOURT OF COMMON a 4 AUG 14 a CIVIL DIVISION CUHBERL4ND COUNT PENNSYLVANIA 1/ Civil Action No. 14-3362 CIVIL PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant MICHAEL D COOPER above named, in the default of an Answer, in the amount of $12086.00 computed as follows: Amount claimed in Complaint Less payments / Attorney's fees TOTAL adjustments made I hereby certify that been mailed in accordance Notices. $12086.00 $0.00 $0.00 $12086.00 appropriate Notices of Default, as attached have with PA R.C.P. 237.1 on the dates indicated on the WELTMAN, WEINBERG & REIS CO., L.P.A. By: iN fA�. �✓ William T. Molczan 30286820 C A Pit SJS Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 7th Ave Ste 2500 Pittsburgh PA 15219-1842 And that the last known address of the Defendant is : MICHAEL D COOPER 59 E MAIN ST MECHANICSBURG, PA 17055 7437 otittFitop.spel a -16A 1octg3s \Ivilce made' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MICHAEL D COOPER Defendant TO: MICHAEL D COOPER 59 E MAIN ST MECHANICSBURG, PA 17055 Date of Notice: -��. 1tA Case No. 14-3362 CIVIL IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA. 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. By: Matthew Urban P.A.I.D.# 90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Ave Ste 2500 Pittsburgh, PA 15219 Phone: (412) 434-7955 (412) 338-7130 30286820 A PIT M4Z DISCOVER BANK Plaintiff vs. MICHAEL D COOPER IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Civil Action No. 14-3362 CIVIL NON-MILITARY AFFIDAVIT The undersigned is the duly authorized agent and/or attorney for the Plaintiff in the within matter and states as follows: Affiant states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, MICHAEL D COOPER is not in military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the DMDC does not possess any information indicating that the below individual is in the military service: MICHAEL D COOPER 59 E MAIN ST MECHANICSBURG, PA 17055 Affiant further states that the averments contained herein are true and correct to the best of Affiant's knowledge, information and belief and that these averments are made subject to the penalties of 18 Pa C.S.A. Section 4904 relating to unsworn falsification to authorities. Department of Defense Manpower Data Center StatusReport Pursuant to Servicetnembers Civil Relief Act Last Name: COOPER First Name: MICHAEL Middle Name: Active Duty Status As Of: Aug -06-2014 Results as of : Aug -06-2014 08:29:46 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA .'#' i n _ • `>4 �_ . No=s\'.. NA This response reflects the indiividu8ts' active dutystatus based on the Active Outy Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA ii -. -.:NA .. ,. 1: , !� [ 1. s. "No '' !'w'x. ' NA yt This response reflects where the Individual left aodve duty status wtthiK367 days preceding the Active DLty Status Date "i/ ly The Member or His/Her Unit Was Notified of a Future Cell -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component x. y :d' NA This response reflects whether the inti ndual or hisiher unit has received early notification to: report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (A my, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: OCX51E3370D9F50 DISCOVER BANK Plaintiff vs. MICHAEL D COOPER IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Civil Action No. 14-3362 CIVIL NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the fo lowing Order of Judgment was entered against you on (xx) Assumpsit Judgment in the amount of $12086.00 plus costs. Trespass Judgment in the amount of $ plus costs. If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non -Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Aiard Prothonotary By: PROTHONOTARY (OR DEPUTY) MICHAEL D COOPER 59 E MAIN ST MECHANICSBURG, PA 17055 Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 7th Ave Ste 2500 Pittsburgh PA 15219-1842 (412) 434-7955 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 14-3362 CIVIL MICHAEL D COOPER set' j A4 t a-� S4- • , / 11 Qc il , ? / 71) s $ • C U r 6 I -e , rib( }� it S r`ill �� 1 t, sit pp t -)via l PRAECIPE FOR WRIT OF EXECUTION Defendant(s) SANTANDER BANK, N MEMBERS 1ST FCU Garnishee(s) TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against MICHAEL D COOPER , Defendant 3. against SANTANDER BANK, N.A., MEMBERS 1ST FCU, , Garnishee 4. Judgment Amount $ Less Payments/credits received Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): c' { C' $12,086.00 $0.00 $53.64 $12,139.64 WELTMAN, WEINBERG & REIS CO., L.P.A. By: y, James P. Val Jko, Esquire PA I.D. #79546 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Avenue, Suite 2500 Pittsburgh, PA 15219 (412) 434-7955 442 a g SO LL C/iJ+ f)-�?lo WWR No. 30286820 (c:4 K 75 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MICHAEL D COOPER Defendant(s) SANTANDER BANK, N.A. MEMBERS 1ST FCU Garnishee(s) No. 14-3362 CIVIL PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James P. Valecko, Esquire PA I.D. #79596 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Avenue, Suite 2500 Pittsburgh, PA 15219 (412) 434-7955 WWR No. 30286820 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.cepa.net DISCOVER BANK Vs. NO 14-3362 Civil Term CIVIL ACTION — LAW MICHAEL D. COOPER WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against MICHAEL D. COOPER, 59 E. MAIN STREET, MECHANICSBURG, PA 17055 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of SANTANDER BANK, NA. GARNISHEE(S), as garnishee, 17 W. HIGH STREET, CARLISLE, PA 17013 MEMBERS 1sT FCU, 1711 SPRING ROAD, CARLISLE, PA 17013 (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as 1 determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $12,086.00 Plaintiff Paid Interest $53.64 Law Library $.50 Attorney's Comm. % Due Prothonotary $2.25 Attorney Paid $199.85 Other Costs Date: 9/17/14 • ue 1, Prothonotary (Sed) By: Deputy REQUESTING PARTY: Name : JAMES P. VALECKO, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO.,L.P.A. 436 7TH AVENUE, SUITE 2500 PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 79596 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff - - 2i 1 SEP 24 Aid ID: 07 CUMBERLAND COUNTY PENNSYLVANIA Jody S Smith Chief Deputy Richard W Stewart Solicitor OFTF11.1Z SHf,R1rr Discover Bank vs. Michael D Cooper Case Number 2014-3362 SHERIFF'S RETURN OF SERVICE 09/22/2014 10:13 AM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Santander Bank, 17 W High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Denise Beecher, Teller, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and madethe c,,' tents there of known to her. September 23, 2014 (c) CountySuito Sheriff Teieosoft, Inc. LIAM LINE, DEPUTY SO ANSWERS, RNY R ANDERSON, SHERIFF Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY w�F11ti? it 4I fh�lfi OFFiCc OF T¢^..: EI, WE;IFF 2)-314 SEP 24 f H IG: 07 CUMBERLAND COUNT.� PENNSYLVANIA Discover Bank vs. Case Number Michael D Cooper 2014-3362 SHERIFF'S RETURN OF SERVICE 09/22/2014 11:25 AM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, North Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Laurie Shultz, Member Services, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on September 23, 2014 to hael D. Cooper at 59 E Main Street, Mechanicsburg, PA 17055. September 23, 2014 (c) CountySuito Sheriff, Toleosoft, Inc. L AMC INE, DEPUTY SO ANSWERS, RONNY R ANDERSON, SHERIFF RECEIVED SEP 2 4 2014 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MICHAEL D COOPER Defendant(s) SANTANDER BANK, N.A. MEMBERS 1ST FCU Garnishee(s) Civil Action No. 14-3362 CIVIL 14A4crAlask INTERROGATORIES IN ATTACHMENT FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: James P. Valecko, Esquire PA I.D. #79596 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Avenue, Suite 2500 Pittsburgh, PA 15219 (412) 434-7955 N-3 r ✓ rl • rri CD VD CD r- (—) - f WWR No. 30286820 Cr! : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MICHAEL D COOPER Defendant(s) SANTANDER BANK, N.A. MEMBERS 1ST FCU Garnishee(s) Civil Action No. 14-3362 CIVIL TO: SANTANDER BANK, N.A., 17 W HIGH ST, CARLISLE, PA 17013 MEMBERS 1ST FCU, 1711 SPRING RD, CARLISLE, PA 17013 RE: MICHAEL D COOPER , 59 E MAIN ST, MECHANICSBURG, PA 17055 Suggested Reference No.: XXX -XX -0957 XXX -XX - IMPORTANT NOTICES TO GARNISHEE! RECEIVED SEP 2 4 2014 A. You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in Judgment against you. B. Herein, the word "defendant" means any one or more of the defendants against whom the writ of Execution is issued. C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the resultant liability of a Garnishee -Bank would not be measured by the balance in the debtor's account, either at the time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited and withdrawn during the intervening period. WWR. No. 30286820 INTERROGATORIES IN ATTACHMENT RECEIVED SEP 242014 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason (including funds on deposit for checking or savings accounts and certificates of deposit)? 'VQ 1 a. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof; the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the amount or amounts that defendant claims or claimed that you owe or owed to him; and the nature and amount of each of such liabilities. 2. At the time you were served or at any subsequent time was there in your possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or part by the defendant or in which defendant held or claimed any interest? 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? 5. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? 6. At any time after you were served did you pay, transfer, or deliver any money or property to the defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, Identify each account and state the reason for the exemption, the amount being withheld under each exemption and the amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. •l0 WWR No. 30286820 RECEIVED 8. If you are a bank or other financial institution, at the time you were served or at any subsegd 2 4 2014 time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. \Ab 9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. 10. If the answer to Interrogatory 1 is in the affirmative, state the date the written instrument, checking or savings account, certificate of deposit, or other funds were frozen, restricted, or otherwise put on hold by this institution. 11. If the response to Interrogatory 7 is in the affirmative, are other funds comingled in the account which are not deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? 12. If the response to Interrogatory 11 is in the affirmative, state the amount of non-exempt funds on deposit in the account. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James P. Val ko, Esquire PA I.D. #795 6 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Avenue, Suite 2500 Pittsburgh, PA 15219 (412) 434-7955 WWR No. 30286820 RECEIVED SEP 2 4 2014 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is \\cz;\ct__V (Name) 11s4 - °f CAL , garnishee herein, (Title) (Company) that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. (SIGN WWR No. 30286820 O &Zis - 1'4.7 0 INTERROGATORIES IN ATTACHMENT 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to hi for any reason (including funds on deposit for checking or savings accounts and certificates of deposit)? s) c 1 a. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof; the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the amount or amounts that de endant claims or claimed that you owe or owed to him; and the nature and amount of each of such liabilities. 0 2. At the time you were served or at any subsequent time was there in your possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. c\l, N -c_4 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or part by the defendant or in which defendant held or claimed any interest? 0 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? 5. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? 0 6. At any time after you were served did you pay, transfer, or deliver any money or property to the defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? 0 c 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, Identify each account and state the reason for the exemption, the amount being withheld under each exemption and the amou,t of funds in each account, and the entity electronically depositing those funds on a recurring basis. WWR No. 30286820 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. n 9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. 10. If the answer to Interrogatory 1 is in the affirmative, state the date the written instrument, checking or savings account, certificate of deposit, or other funds were frozen, restricted, or otherwise put on hold by this institution. 11. If the response to Interrogatory 7 is in the affirmative, are other funds comingled in the account which are not deposited electronically on a recurring basis and which are identified as beig funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? 12. If the response to Interrogatory 11 is in the affirmative, state the amount of non-exempt funds on deposit in the account. N I� WELTMAN, WEINBERG & REIS CO., L.P.A. By: James P. Val cko, Esquire PA I.D. #795 6 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Avenue, Suite 2500 Pittsburgh, PA 15219 (412) 434-7955 WWR No. 30286820 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is (Name) , garnishee herein, (Title) (Company) that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. (SIGNATURE) WWR No. 30286820 ANSWERS TO INTERROGATORIES Account # 1674303068 Balance: $0.00 Account Holder: MICHAEL D COOPER 59 E MAIN ST MECHANICSBURG, PA 17055-3852 Acct. # 1671077636 Balance: $0.00 Acct. Holder: MICHAEL D COOPER S/A VERIFICATION I, Debbie Lewis, C.O.P. Process Specialist of Santander, hereby verify that the information contained in the foregoing Answers to Interrogatories in Attachment are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094, relating to unsworn falsification to authorities. Santand By: Debbie Lewis C.O.P. Process Specialist THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: 14_ y3?lApa DISCOVER BANK vs. MICHAEL D COOPER CERTIFICATE OF SERVICE I hereby certify that on or before the date of filing the following documents(s): Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption I have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows: JAMES P. VALECKO, ESQ WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7TH AVE SUITE 2500 PITTSBURGH, PA 15219 Service by certified mail addressed as follows: MICHAEL D COOPER 59 E MAIN ST MECHANICSBURG, PA 17055-3852 ie Lewis C.O.P. Process Specialist Santander MAI MB3-02-10 2 Morrisey Boulevard Boston, MA 02125 October 24, 2014 WELTMAN, WEINBERG & REIS CO., L.P.A. BY: James P Valecko, Esquire I.D. No. 79596 436 Seventh Avenue, Suite 2500 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 30286820 r 11_ t -r7 •L- r OF E JTOOOTAF, Attorney for Plaintiff(s), 2 iii1I1: 51 DISCOVER BANK Cumberland County Court of Common Pleas vs. MICHAEL D COOPER and SANTANDER BANK N.A., MEMBERS 1ST FCU Garnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION NO. 14-3362 CIVIL TO THE PROTHONOTARY: Kindly mark the above matter discontinued and ended as to Garnishee(s), SANTANDER BANK N.A., MEMBERS 1ST FCU, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By James P alecko, Esquire Attorney for Plaintiff ao.k sq.So k‘8itqU- '3136)